View full case

NELEN LAMBERT v. HEIRS OF RAY CASTILLON

FACTS:

Ray Castillon borrowed his brother's motorcycle and invited his friend Sergio Labang for a ride around Iligan City. After having dinner and drinking beer, they were driving at a high speed towards Tambo when they collided with a Tamaraw jeepney owned by petitioner Nelen Lambert and driven by Reynaldo Gamot. Ray died on the spot, and Sergio was injured. The heirs of Ray filed a lawsuit for damages against Nelen Lambert, which was later amended to include a claim by Joel Castillon for damage to the motorcycle. The trial court held Nelen Lambert liable but reduced the damages by 20% due to Ray's contributory negligence. The Court of Appeals affirmed the decision, and Nelen Lambert filed a petition for review. The issue raised was whether Nelen Lambert's driver was negligent and if Nelen Lambert was liable for damages. The court found that the cause of the accident was Reynaldo's abrupt and sudden left turn without establishing his right of way.

ISSUES:

  1. Whether the negligence of Ray Castillon was the proximate cause of his death, thus absolving petitioner from liability.

  2. Whether the trial court erred in its computation of the loss of earning capacity of Ray Castillon.

  3. Whether the trial court's award of moral damages was appropriate.

RULING:

  1. Proximate Cause and Liability: The Supreme Court held that the abrupt and sudden left turn by Reynaldo, without establishing his right of way, was the proximate cause of Ray Castillon's death. However, Ray was also guilty of contributory negligence, warranting an equitable apportionment of damages.

  2. Computation of Loss of Earning Capacity: The Court found that the trial court erred in its computation and provided a detailed formula to arrive at the correct net earnings, which is 50% of the gross annual income.

  3. Moral Damages: The award of moral damages amounting to P50,000.00 was sustained as it is consistent with prevailing jurisprudence.

PRINCIPLES:

  1. Proximate Cause: Defined as the cause which, in natural and continuous sequence unbroken by any efficient intervening cause, produces the injury and without which the result would not have occurred.

  2. Contributory Negligence (Article 2179, Civil Code): If the plaintiff's negligence was only contributory, and the immediate and proximate cause of the injury was the defendant's lack of due care, the plaintiff may recover damages, but the courts shall mitigate the damages to be awarded.

  3. Mitigation of Damages: The ratio of apportionment of damages on account of contributory negligence varies based on case circumstances (e.g., 50%, 20%, 40% mitigation in different cases).

  4. Loss of Earning Capacity: The formula for computation of net earning capacity is [2/3 x (80 - age at time of death) x (gross annual income - 50% of gross annual income)].

  5. Moral Damages (Article 2206, Civil Code): Provided for mental anguish by reason of the death of the deceased. Typically pegged at P50,000 in recent jurisprudence.

  6. Attorney's Fees (Article 2208, Civil Code): Must be justified by a factual, legal, or equitable basis. Attorney's fees should not be awarded without a basis in the body of the court’s decision.